This Privacy Policy governs your use of the website www.bolttech.eu (the "Website") made or created by bolttech (referred to as "bolttech", "we" or "us" in this document). The Website allows you to read information about bolttech and its affiliates and send an email of enquiry to bolttech. In this privacy policy, "bolttech" may refer to any member of the bolttech group of companies, in particular the company or companies that are processing your personal data; and "we", "us" and "our" also refer to the group and individual companies.

To the extent that General Data Protection Regulation "GDPR" applies to you, we will let you know which company in the group is the data controller in respect of your personal data when you purchase goods or services from us, or otherwise engage in any sort of transaction with us that results in your personal data being processed.

The following entities are data controllers of your personal data collected through the contact forms on the Website:

• Bolttech Device Protection (United Kingdom) Limited
• Bolttech Management (Hong Kong) Limited
• Bolttech Challenger GO Pte (Singapore) Limited
• 4 SEASONS EOOD (Bulgaria)
• bolttech device protection (Italy) s.r.l.

We will not automatically collect any personal information that identifies a visitor to the Website. Your visit to the Website will record only the Domain Name Server part of your email address and the pages visited. bolttech is committed to the implementation and compliance with the provisions of the relevant legislation including GDPR at all times.

We will also ensure our compliance to the strictest standards of security and confidentiality of all personal information and data submitted by you (whether you are registered or not) either via a website form or email or subdomains (hereinafter collectively referred to as the "Channels") and we will not release such information to any party without your prior consent, except under the exclusions listed under the sub-paragraph entitled "Disclosure or Transfer of Data" below.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. We may update, revise, vary, or amend this Privacy Policy, without notice to you, by posting the new policy on our website, so you should always check whether a new policy applies when you visit the site.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We have appointed a data privacy manager (DPM) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise Legal Rights, please contact the data privacy manager using the details set out below.

Purpose of Collection of Personal Data

In the course of using the Channels, you may disclose or be asked to provide personal information. In order to benefit from and enjoy the various services offered by the Channels, it may be necessary for you to provide bolttech with your personal information. Although you are not obliged to provide the information requested on the Channels, if you do not provide such data, we may not be able to render certain services on the Channels.

Our purposes for collection of information and data (including personal data) on the Channels include but are not limited to the following:

• to perform the operation of the services requested by you;

• to identify users who have viewed the Information posted on the Channels;

• to compile and analyse aggregate statistics about users' use of the Channels and service usage by users for bolttech's internal use.

bolttech collects only personal data which is necessary and adequate but not excessive in relation to these purposes, further details of which appear below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

*Full name of legal entity: Bolttech Holdings (Europe) SARL Luxembourg

Email address: dpm@bolttech.io

Postal address: 5 Place de la Gare, L-1616 Luxembourg, Grand Duchy of Luxembourg

Or in Asia:

Full name of legal entity: Bolttech Management Limited

Email address: dpm@bolttech.hk

Postal address: Room 1902, 19/F, Lee Gardens One, 33 Hysan Ave Causeway Bay, Hong Kong*

You have the right to make a complaint at any time to the relevant data protection authority in your country, for example Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the authority so please contact us in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Unless you are applying for a position with us, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Further information for job applicants is contained in a supplementary privacy notice which will be provided to you as part of the application process.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide those data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2. How are your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions.

You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• give us feedback or contact us

• submit a servicing request.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

• Third parties or publicly available sources.

We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU;

(b) search information providers such as Google based outside the EU.

• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside or outside the EU.

3. How we use your personal data

• We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

View our Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message, where relevant legislation applies. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To process and respond to a contact request submitted on our website, through the following forms:

(a) Contact us

(b) Request a demo

(a) Identity

(b) Contact

Necessary for our legitimate interests (to respond to a contact request from you)

To process and respond to a job application submitted through our Careers page

(a) Identity

(b) Contact

(c) Profile

Necessary for our legitimate interests (to process a job application submitted by you)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above:.

• Internal Third Parties as set out in the Glossary

• External Third Parties as set out in the Glossary

• Specific third parties such as Netlify, who provide hosting services for the website.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

Your personal data may also be processed for the purposes set out above under the section “Purposes for which we will use your personal data” by bolttech's subsidiaries, holding companies, associated or affiliated companies and companies controlled by or under common control with the Company (collectively, "the Group"). This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK authorities.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the European Union or the United Kingdom, as the case may be.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

Under certain circumstances, you have Legal Rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out in the link, please contact our Data Privacy Manager (dpm@bolttech.io).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.